Pignon sur terre Inc. & its Broker Representatives (hereinafter the “AGENCY”) are governed by the Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1) (the “Act”).
“Personal information” means any information relating to a natural person that directly or indirectly identifies that person. Written documents, images, videos, and audio recordings may contain personal information.
In the course of its professional activities in real estate brokerage, the AGENCY may collect personal information such as a person’s name, residential address, date of birth, identification document details, social insurance number, income information, marital status, etc.
The AGENCY collects, uses, and discloses personal information with the consent of the individual concerned.
To be valid, consent must be clear, free, informed, and given for specific purposes. A person who consents to providing personal information is presumed to consent to its use and disclosure for the purposes for which it was collected.
Any person may withdraw their consent at any time to the collection, use, and disclosure of their personal information by the AGENCY. However, if such information is necessary for the formation or performance of a contract, the AGENCY may be unable to provide the requested services.
The AGENCY is responsible for protecting the personal information it holds in the course of its real estate brokerage activities.
To that end, the AGENCY has adopted a Privacy Policy and governance policies and practices governing the collection, use, disclosure, retention, and destruction of personal information.
The AGENCY collects only the personal information necessary to carry out its real estate brokerage activities.
Such information may be collected for purposes including:
The AGENCY requires its staff members to clearly explain, in plain language, the reasons for collecting personal information and to ensure the individual understands them.
For collection purposes, the AGENCY encourages the use of standardized forms developed by the OACIQ.
Personal information may also be collected verbally during communications with parties involved in a real estate transaction or through documents submitted in connection with a transaction (identification documents, financial documents, powers of attorney, etc.).
Personal information is used and disclosed for the purposes for which it was collected and with the consent of the individual concerned.
In certain cases provided by law, personal information may be used for other purposes, such as detecting and preventing fraud or providing services to the individual concerned.
The AGENCY may be required to disclose personal information to third parties, including:
The AGENCY may disclose personal information without consent where such disclosure is necessary for the performance of a mandate or service contract. In such cases, the AGENCY enters into a written agreement requiring the mandatary to:
Before disclosing personal information outside Québec, the AGENCY considers the sensitivity of the information, the purpose of its use, and the protection measures in place in the receiving jurisdiction. Personal information will only be disclosed outside Québec if it is determined that it will receive adequate protection.
Once the purposes for which personal information was collected or used have been fulfilled, the AGENCY must destroy it, subject to any statutory retention period.
In accordance with professional obligations applicable to real estate brokerages in Québec, files must be retained for a minimum of six (6) years following their final closing.
During the collection, use, retention, and destruction of personal information, the AGENCY implements appropriate security measures to protect confidentiality.
The AGENCY maintains a confidentiality incident register in accordance with applicable legislation.
In the event of a confidentiality incident presenting a risk of serious injury, the AGENCY will notify the affected individual in compliance with applicable legislation.
Risk assessment considers factors such as:
A confidentiality incident includes unauthorized access, use, or disclosure of personal information contrary to the Act, loss of personal information, or any other breach of its protection.
The AGENCY has implemented a confidentiality incident management protocol identifying the individuals assisting the Privacy Officer and outlining concrete steps to be taken in the event of an incident, including responsibilities and required data security measures.
In accordance with the Act, the AGENCY has appointed a Privacy Officer.
The Privacy Officer:
Staff members may access personal information only where necessary for the performance of their duties.
Staff members must:
An individual (or authorized representative) may request access to personal information concerning them that is held by the AGENCY.
An individual may withdraw consent at any time. Such withdrawal must be documented in writing.
An individual may request correction of personal information that is inaccurate, incomplete, or ambiguous.
The AGENCY may refuse access or rectification in cases provided by law.
Any individual who believes they have suffered harm may file a complaint regarding the handling of their personal information by the AGENCY.
Complaints will be handled diligently within a maximum of 15 days by the Privacy Officer, and a written response will be provided.
Person Responsible for Access to Information and the Protection of Personal Information
Roxane Saulnier, Chartered Real Estate Broker (AEO) – Privacy Officer
12 River Street, Suite D
Stanbridge East, Québec
J0J 2H0
Email: roxane@roxanesaulnier.ca
Complaints must include:
Anonymous complaints will not be processed.
Identity verification is required before responding to any request, question, comment, or complaint.
For access or rectification requests or to file a complaint, please contact:
Roxane Saulnier, Chartered Real Estate Broker (AEO) – Privacy Officer
12 River Street, Suite D
Stanbridge East, Québec
J0J 2H0
roxane@roxanesaulnier.ca
